BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

requirements for SAR filing (see “SAR Filing” below) in cases involving reportable activity. These procedures and processes will include: ● Protocols for investigation of alerts; ● Escalation processes for potentially suspicious alerts; ● Documentation standards for investigations, which will include documenting the rationale for closing any alert found not to be suspicious; ● Mechanisms to feedback the results of investigations into KYC processes; and ● Quality assurance of investigations. 4. SUSPICIOUS ACTIVITY MONITORING AND REPORTING The BSA/AML Officer will ensure that the Bank: ● Documents its SAR decisions; ● Files or amends SARs in a timely fashion (and always within timeframes prescribed by the Financial Crime Enforcement Network (“FinCEN”)); ● Creates and retains appropriate records of reported activity; and ● Complies with all FinCEN and other regulatory SAR filing guidance. TS&J sets out its transaction monitoring and SAR processes in more detail in its SAR Procedures. SAR Filing The BSA/AML Officer will establish a process to ensure that staff review alerts in a timely fashion and will consider whether the Bank needs to act, including blocking and/or closure of the account and, if appropriate, the filing of a SAR. The BSA/AML/OFAC function will close accounts on which it files a SAR (if applicable and authorized by the BSA/AML Officer), unless it has received specific written instructions from law enforcement or a government agency to keep the account open, or the Bank believes advisable to continue to monitor or there is a reasonable belief such holder is a victim of fraud and per procedures it is determined to not block the account or card holder from future business. The BSA/AML/OFAC function will file a SAR with FinCEN for any transaction that is conducted or attempted by, through or to the Bank that meets any of the following criteria: ● Criminal violations involving insider abuse in any amount;

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